What's everyones view out there on the new QM policy sent out by the CFPB today and how it will affect Wholesale lending?

As brokers, we've been following these new rules since January 1, 2010, so nothing new. The one change will be this 3% fee cap and will definitely hurt the smaller mortgage amounts (under $100,000). I'm 75 miles north of NYC, and the average price home is over $200,000, so I won't be too affected. I'll just refer the smaller loans to the local credit union and tell the borrower that even though I can get them a lower rate and lower costs in most cases, it's not profitable enough for me to take their application. They can write a formal complaint to the CFPB.

As long as wholesale lenders don't take away lender credits (formerly YSP), I think most brokers will be fine.

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